- 3 -
Petitioner resided in Quincy, Massachusetts, at the time the
petition was filed.
On April 15, 2002, respondent issued to petitioner a Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing. The notice pertains to petitioner’s unpaid Federal
income tax for 1999, in the amount of $16,560 (the unpaid tax).
By letter dated April 23, 2002, petitioner’s representative,
Timothy J. Burke, Esq., submitted an Internal Revenue Service
(IRS) Form 12153, Request for a Collection Due Process Hearing,
to the IRS on petitioner’s behalf. On an attachment to the Form
12153, petitioner asserts: “It is in the best interest of the
government and the taxpayer that an Offer in Compromise be
entered into.” Petitioner raised no other issue on the Form
12153 or during the subsequent hearing accorded him (the section
6330 hearing or, sometimes, the hearing).
On or about September 13, 2002, an Appeals official,
Settlement Officer Lisa Boudreau, was assigned to petitioner’s
case. On September 16, 2002, Ms. Boudreau sent Mr. Burke a
letter scheduling a meeting for September 20, 2002. At Mr.
Burke’s request, that meeting was rescheduled for October 3, 2002
(the October 3 meeting). Ms. Boudreau and Mr. Burke, but not
petitioner, attended the October 3 meeting. At the meeting, Mr.
Burke submitted to Ms. Boudreau certain collection information
statements that had been requested by her and an IRS Form 656,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011